| File Note: |
It is submitted that the industry was granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Varied/PBIP/PTL/2023/2305751675 dated 23.07.2023 and under the Air (Prevention & Control of Pollution) Act 1981 vide no. CTOA/Varied/PBIP/PTL/2023/2305486087 dated 23.07.2023, both valid up to 31/03/2024, for manufacturing of ERW @ 110 TPD & CDW @ 100 TPD by using Hot rolled steel strips @ 210 TPD & cold rolled steel strips @ 30 TPD, as raw material under red category.
Now, the industry has applied for renewal of consent to operate under the Water (Prevention & Control of Pollution) Act 1974 & the Air (Prevention & Control of Pollution) Act 1981 for manufacturing of ERW @ 110 TPD & CDW @ 100 TPD by using Hot rolled steel strips @ 210 TPD & cold rolled steel strips @ 30 TPD, as raw material under red category.
The earlier fee deposited by the industry amounting to Rs. 9,83650/- (Rs. 5,76000/- Vide PBIP R.NO.11159 Dated 24/03/2023 & Rs. 4,07,650/- vide PBIP 12574 dated 21/06/2023) under each Act was adequate upto 30.11.2027 against fixed assets as on 31.3.2023 @ 194.16 crores. Now, the industry has submitted a latest CA certificate mentioning its total fixed assets as on 29.02.2024 for Rs. 199.38 Cr.
Therefore, after deducting NOC regularization fee of Rs. 21600/- from the above said consent fee, the aggregate fees under each Act, is now adequate upto 31/10/2027 under Red Category, against the total fixed assets of the industry @ 199.38 Crores as on 29.02.2024.
As per the record file, the industry was visited surprisingly by the team of the officers of the Board on 22/7/2023 and contacted Sh. Rajiv Gautam, Head Production. During visit, it was observed as under:
1. The industry is engaged in manufacturing of steel tube and was found in operation.
2. The industry has 3 tube mills of capacity 100 TPH.
3. The industry has installed 2 no. annealing furnace (PNG fired) having capacity 3.0 TPH each. Stack of adequate height is provided with each as APCD.
4. The industry is also involved in surface treatment process having component;
De-greasing → Rinsing → Pickling → Rinsing → Phosphating Rinsing → Oil dip → final.
5. There are 2 section for carrying out metal surface treatment. During visit, only one section was found in operation.
6. The industry has provided fume extraction system followed by Alkali scrubber as APCD on pickling section using HCL. During visit, the suction capacity of fume extraction system was found not adequate, as fumes were found escaping the suctions valves.
7. Water from rinsing + de-greasing section + phosphating section is being sent to ETP.
8. Phosphating sludge is removed manually and is stored in bags. The bags were found lying in open condition near ETP.
9. Spent acid is stored in storage tank capacity 20 KL. At present 13 KL of spent acid is lying stored.
10. Spent acid is lifted by M/s JBR Technology as informed by representative. as per record, 12.5 KL of spent acid was lifted 3-days back by M/s JBR Technology.
11. The industry has provided STP for treatment of domestic effluent (capacity of STP 40 KLD).
12. The industry has also provided ETP of capacity 105 KLD for treatment of its trade effluent.
13. The outlet ETP (RO permeate) is being used back into wet process.
14. RO reject of ETP + UF permeate of STP is utilized onto land for plantation.
15. The industry has approx. 3.5 acre of land under Karnal Technology. However, the industry has not provided equal hydraulic distribution network for utilization of treated waste water onto land for plantation. As a results stagnation of waste water was observed in some part plantation area and the other parts were found in dry condition. Total 7.5 acre of land is developed in form of lawns.
16. The industry has not provided numbering on hazardous waste bags stored in HWM rooms.
Accordingly, the industry was issued show cause notice for revocation/cancellation of consent to operate granted under of the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 vide Board’s letter no. 6714-15 dated 30/08/2023 alongwith opportunity of personal hearing before the Chairman of the Board on 06.09.2023. After hearing, it was decided that:
1. The industry shall provide adequate storage for collection of wastewater being generated from the pickling process and shall not dispose of the same until it makes its own arrangements for treatment/disposal of the same.
2. The industry shall not make any dilution of high TDS water with its treated domestic effluent and shall make arrangements for its treatment separately.
3. The industry shall submit Action Plan for installation/execution of captive HCL Recovery Plant, within, one month.
4. The industry shall improve its plantation area and ensure the uniform distribution of treated wastewater in the same and no stagnation be there in the plantation area at any time.
5. Environmental Engineer, Regional Office, Patiala shall carry out the complete sampling of the wastewater including R.O. reject, untreated wastewater at the inlet of ETP, treated water leading to the plantation area etc., and submit its report, within one month.
6. The industry shall submit a Bank Guarantee amounting to Rs.5 Lacs as an assurance to comply with the Environmental Laws, within 7 days.
7. If the industry is again not found complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981, strict action shall be taken against the industry including imposition of Environmental Compensation etc. without any notice/opportunity.
8. Further action shall be taken after the receipt of the report from Regional Office, Patiala.
The proceedings of the hearing were conveyed to the industry vide Board's letter no. 7624 dated 04/10/2023.
In response to the decision taken during the personal hearing held on 06.09.2023, the industry has submitted point wise reply, which is reproduced in the attachment file.
As per the reply, the industry has submitted that captive HCL recovery plant is not viable due to very less generation of HCL. However, the industry has submitted to install acid life extender system, which will increase acid life by 3-4 times, thereby reducing the generation of waste acid per month. In addition, the bank guarantee amouting of Rs. 5.0 submitted by the industry bearing no. 004GT022329000004 dated 17.10.2023 is valid upto 15.10.2024.
Further, as per the record file, stack emission sampling of the industry was carried out by the Board on 28.09.2023 and the results are tabulated in the attachment file.
Moreover, effluent sample of the industry was also carried out by the Board laboratory on 18.01.2024 and the results of the same are also mentioned in the attachment file.
As per the results of emission and effluent sampling carried out by the Board's lab, the concentration of various parameters is found to be within permissible limits as prescribed by the MoEF&CC for such type of industry.
Now, to check the latest compliance, the industry was visited by the AEE of this office on 26.03.2024 and contacted Rajiv Gautam, Manager. During visit, it was observed as under:
1. The industry was found in operation.
2. The industry has installed 2 no. annealing furnace (PNG fired) having capacity 3.0 TPH each, which are equipped with stack of adequate height as APCD.
3. The industry is also involved in surface treatment process. During visit, only one section was found in operation.
4. The industry has provided fume extraction system followed by Alkali scrubber as APCD on pickling section using HCL. The industry has now improved the RPM speed of motor installed with alkali scrubber and hence suction was found adequate during the visit.
5. Water from rinsing + de-greasing section + phosphating section is being sent to ETP.
6. The industry has provided storage tank capacity 20 KL for storage of Spent acid. At present 5.0-6.0 KL of spent acid is lying stored.
7. Last lifting to M/s JBR Technology for spent acid was done for 12.0 KL of spent acid on 22/03/2024.
8. The industry has provided STP for treatment of domestic effluent.
9. The industry has also provided ETP with collection tank having capacity 140 KLD.
10. The outlet ETP (RO permeate) is being used back into wet process.
11. The industry has now started using RO reject onto internal roads for supersession of dust.
12. The treated effluent from STP plant is utilized onto land for plantation in an area of approx. 8 acres. During visit, no stagnation was observed in plantation area.
13. The industry has now maintained the record of various hazardous waste stored in the HWM room, properly.
As mentioned above, the unit is complying with the provision of Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention and Control of Pollution) Act, 1981.
In view of above mentioned facts, consent to operate granted under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 may be further renewed up to 31.10.2027 for manufacturing of ERW @ 110 TPD & CDW @ 100 TPD by using Hot rolled steel strips @ 210 TPD & cold rolled steel strips @ 30 TPD, as raw material under red category, subject to suitable conditions as per policy of the Board.
Competency: (Red / Large) : Worthy Chairman |
